S.J.MUKHOPADHAYA, J. - (1.) THESE writ petitions having been preferred by same petitioner M/s Voltas Limited and common question of law being involved, they were heard together and are being disposed of by this common judgment.
(2.) FOUR of the writ petitions relate to the assessment years 1985 -86 to 1988 -89, wherein, the petitioner has exhausted all its statutory remedies, such as, appeal, review and revision but being unsuccessful and aggrieved, has preferred these writ petitions. The case numbers and their respective assessment year are as follows: Case No. Assessment year W.P.(T)No. 482/05 1985 -86 W.P.(T)No. 467/05 1986 -87 W.P.(T)No. 493/05 1987 -88 W.P.(T)No. 466/05 1988 -89 Other three writ petitions relate to the assessment years 1990 -91 to 1992 -93. The petitioner has challenged the orders of remand, as made by the appellate authority on the ground of limitation. Case numbers of these three writ petitions and their respective assessment year are as follows: Case No. Assessment Year W.P.(T)No. 358/05 1990 -91 W.P.(T)No. 542/05 1991 -92 W.P.(T)No. 533/05 1992 -93 The petitioner, a Company registered under the Indian Companies Act, 1913, is engaged in execution of works contract, relating to commissioning of air -conditioning plants in various organizations. It also sells its air -conditioning machines. According to the petitioner, all the works contract relating to commissioning of air -conditioning plants have almost similar terms and conditions and such plants are commonly known as air -conditioning system or facility. It undertakes air conditioning contracts where the contracts cover the design, supply, installation, testing and commissioning of the entire air -conditioning plants and -such plants are extended a guarantee for the performance of satisfactory functioning. The air -conditioning plant is supposed to deliver certain desired comfort to its users, which depends on temperature, relative humidity and cleanliness. Such plant includes all machineries, accessories and parts, which are required to make the plant functional.
(3.) FURTHER case of the petitioner is that it manufactures the main refrigeration equipments in its factory at Thane and Dadra (Maharastra), such as, compressors, condensers, evaporators (chillers and colls), packaged air -conditioning units, split unit, reciprocating chillers, centrifugal chillers and vapour absorption machines. Other machineries, as required, are bought out items, such as, air -handling units, pumps, cooling towers, electrical panels, pipes, valves, G.P.sheets, insulation materials, cabling etc.;